Privacy Notice for Candidates
Version 1.5, 2022-01-24
What is the purpose of this document?
Bettys & Taylors Group Ltd is committed to protecting the privacy and security of your personal information. This privacy notice applies to all candidates (whether you are applying to work with us as an employee, worker or contractor) and describes how we collect and use personal information about you during the recruitment process, and how long it will be retained for, in accordance with the General Data Protection Regulation (GDPR).
Bettys & Taylors Group Ltd is a “data controller”. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.
What is Personal data?
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). There are “special categories” of more sensitive personal data which require a higher level of protection.
The kind of information we hold about you
We may collect, store and use the following categories of personal information about you:
- Address and contact details, including email address and telephone numbers.
- Date of birth.
- Details of your qualifications, skills, experience and employment history.
- Information about your current level of remuneration, including benefit entitlements.
- CCTV footage and other information obtained through electronic means such as fob records; car registration details via our Automatic Number Plate Recognition system.
We may also collect, store and use the following “special categories” of more sensitive personal information:
- Information about your nationality.
- Information about your health.
- Information about criminal convictions and offences.
How we collect and store your personal information
We collect personal information through the application and recruitment process, either directly from candidates or from an employment agency. We collect this information in a variety of ways e.g. data might be contained in application forms, CVs, covering letters, obtained from your passport or other identity documents, or collected through interviews or other forms of assessment.
We may sometimes collect additional information from third parties including former employers and the Disclosure and Barring Service. We will seek information from third parties only once a job offer has been made to you and will inform you that we are doing so.
Data will be stored in a range of different places including in recruitment records, in our HR systems and on other IT systems including email.
How we use your personal information
We have a legitimate interest in processing personal data during the recruitment process and for keeping records of the process. Processing data from candidates allows us to manage the recruitment process, assess and confirm suitability for employment and make decisions about job offers. Where we rely on legitimate interests as a reason for processing data, we have considered whether or not those interests are overridden by the rights and freedoms of candidates and have concluded that they are not.
We also need to process data to ensure that we are complying with our legal obligations, e.g. checking eligibility to work in the UK before employment starts, and we may need to use the Home Office Employer Checking Service. If this is the case we will ask for your consent. Furthermore, we need to process data to take steps at your request prior to entering into a contract with you. We also need to process your data to enter into a contract with you.
We have a legitimate interest to protect our property, customers and people and we therefore operate a CCTV system, and an Automatic Number Plate Recognition system, in our car park which records images for security.
We may also need to process data from candidates to respond to and defend against legal claims.
We may also process your personal data to assist the NHS Test and Trace service; our legal grounds for doing so relate to our legitimate interests and substantial public interest.
We may also process your personal data to help prevent the transmission of Covid-19 in our workplaces and the wider community; our legal grounds for doing so relate to our legitimate interests and substantial public interest.
How we use particularly sensitive personal information
“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place appropriate safeguards which we are required by law to maintain when processing such data.
We may process special categories of personal information where we need to carry out our legal obligations or exercise rights in connection with employment. Specifically, we will use your sensitive personal information in the following ways:
- We will use information about your health to make reasonable adjustments during the recruitment process, if required.
- We will use information about your health via a Health Questionnaire, which we will ask you to complete after we have made a job offer, so that our Occupational Health team can assess your fitness for the role you have been offered. During the processing of our Health Questionnaire, if you have a medical condition that requires adjustments in the workplace or if it is important for your Line Manager to be aware to support you in your role, or there is a Health and Safety reason for doing this, then the Occupational Health Clinicians will advise the Health and Safety team who will communicate this to your Line Manager and HR. If you are an agency worker this will be via the recruitment agency. Additionally, if, as a consequence of your medical condition, you are deemed to have a protected characteristic under the Equality Act 2010, your Line Manager and HR will be advised of this fact. For agency workers this will be communicated to the Line Manager via the Recruitment Agency.
- We will use information about your nationality to check that you are legally entitled to work in the UK.
- We will share your contact information and details of when you were present at any of our sites/premises with the NHS Test and Trace Service if requested by them to do so.
- We will use the results of the at-home lateral flow tests that you share with us to assess whether it is safe for you to enter our workplaces. We require you to share those results with Public Health England.
Information about criminal convictions
We will only collect information about criminal convictions if it is appropriate given the nature of the role and where we are legally able to do so. Where appropriate, we will collect information about criminal convictions as part of the recruitment process in the following ways:
- To ensure we comply with legal requirements in relation to Disclosure and Barring Service checks.
- To ensure suitability for certain roles where certain criminal convictions may pose a serious risk to our business.
- To ensure fitness for driving duties, either on company business or as part of your role.
We are allowed to use your personal information in this way to carry out our obligations and exercise specific rights in relation to employment and for our legitimate interests. We have in place appropriate safeguards which we are required by law to maintain when processing such data.
Our recruitment processes are not based on automated decision-making.
Who has access to your personal data?
Your information will be shared internally for the purposes of the recruitment exercise. This may include members of the HR team, Team Leaders/Managers involved in the recruitment process, Occupational Health, and IT if access to the data is necessary for the performance of their roles.
We may share your personal information with third parties where required by law, or where we have another legitimate interest in doing so (for example we may need to provide information to our insurers if you are involved in, or witness, an accident during a visit to one of our sites for interview). We may also need to share your personal information with a regulator or to otherwise comply with the law. We require third parties to respect the security of your data and to treat it in accordance with the law.
We will not share your data with third parties, apart from in the circumstances explicitly stated above, unless your application for employment is successful and we make you an offer of employment.
We do not envisage that we will transfer the personal data we collect about you outside the EU, however we will update this Privacy Notice if this position changes.
How do we protect your personal data?
We take the security of your data seriously. We have internal policies and controls in place to ensure that your data is not lost, accidentally destroyed, misused or disclosed, and is not accessed except by people in the proper performance of their duties.
How long do we keep your personal data?
If your application is unsuccessful, we will hold your data on file for 6 months after the end of the relevant recruitment process. During this period we may contact you regarding other employment opportunities we think you may be suitable for. Please inform us if you do not want us to store your data for this purpose. After 6 months your data is deleted or destroyed.
If your application for employment is successful, personal data gathered during the recruitment process will be transferred to your personnel file and retained during your employment. The periods for which your data will subsequently be held will be provided to you in our Privacy Notice for Employees.
Under certain circumstances, by law, you have the right to:
- access and obtain a copy of your personal data on request;
- require us to change incorrect or incomplete data;
- require us to delete or stop processing your data, for example where the data is no longer necessary for the purposes of processing;
- object to the processing of your data where the organisation is relying on its legitimate interests as the legal ground for processing;
- ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the organisation’s legitimate grounds for processing data;
- request the transfer of your personal data to another party.
If you want to exercise any of these rights please contact the Company Secretariat department in writing at the address below.
What if you do not provide personal data?
You are under no statutory or contractual obligation to provide data to us during the recruitment process. However, if you do not provide the information, we may not be able to process your application properly or at all.
Data protection enquiries
If you have any questions about this Privacy Notice or how we handle your personal information, please contact the Company Secretariat department in writing at Bettys & Taylors Group Ltd, Group Office, 1 Parliament Street, Harrogate, HG1 2QU.
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues.
Changes to this Privacy Notice
We reserve the right to update this Privacy Notice at any time.